Ernest Sirois v. Minister of National Revenue, [1990] 2 CTC 2331, 90 DTC 1840 -- text
Kempo, T.C.J.:—This appeal concerns the appellant's 1986 taxation year wherein the respondent had assessed to income the amount of $4,757.59 on the premise that it was dividend income pursuant to subsection 52(3) of the Income Tax Act